Annotation 325.0570

(c) SHIPMENTS FROM CALIFORNIA TO POINTS OUTSIDE STATE

(1) Generally

If the retouched negatives are merely shipped to an out-of-state location prior to making any use of them in this state, on behalf of the purchaser, the sale is exempt from sales tax pursuant to section 6396.

However, if the customer's retouched negatives are used in this state to make prints, the sale of retouching is a retail sale in this state and subject to sales tax. 8/27/93.